Schoger Foundation v. Commissioner
United States Tax Court
P is a not-for-profit corporation that owns and operates a mountain lodge that it characterizes as a religious retreat facility. The lodge makes available to its guests numerous activities, religious, recreational, and social, none of which are regularly scheduled or required. The religious activities revolve around individual prayer and contemplation, with optional daily devotions and occasional Sunday services available to the guests.
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P is a not-for-profit corporation that owns and operates a mountain lodge that it characterizes as a religious retreat facility. The lodge makes available to its guests numerous activities, religious, recreational, and social, none of which are regularly scheduled or required. The religious activities revolve around individual prayer and contemplation, with optional daily devotions and occasional Sunday services available to the guests. The recreational and social activities are those of the usual vacation resort. The record does not show the extent to which the guests participated in any of…
1Opinion of the Court
OPINION
Parker, Judge:
Respondent determined that petitioner does not qualify for exemption from Federal income tax under section 501(a) as an organization described in section 501(c)(3).1 Petitioner challenges respondent’s determination and has invoked the jurisdiction of this Court for a declaratory judgment pursuant to section 7428.2 The issue is whether petitioner is operated exclusively for religious or other exempt purposes within the meaning of section 501(c)(3).
This case was submitted for decision on the stipulated administrative record under Rules 122 and 217, Tax Court Rules of…
2Cases cited11 opinions
- Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946
- B.S.W. Group, Inc. v. CommissionerUnited States Tax Court · 1978
- Church in Boston v. CommissionerUnited States Tax Court · 1978
- Hancock Academy of Savannah, Inc. v. CommissionerUnited States Tax Court · 1977
- Stevens Bros. Foundation, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
6 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Church of Scientology v. CommissionerUnited States Tax Court · 1984
- Living Faith, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1991
- Columbia Park & Recreation Asso. v. CommissionerUnited States Tax Court · 1987
- Bethel Conservative Mennonite Church v. CommissionerUnited States Tax Court · 1983
- New Dynamics Foundation v. United StatesUnited States Court of Federal Claims · 2006
16 more not listed; retrieve them via the Exa API.